4(1)Any unallowed capital losses of NIE shall be apportioned between the successor companies in accordance with the transfer scheme; and any such losses which are so apportioned to a successor company shall be treated as allowable capital losses accruing to the successor company on the disposal of an asset on the transfer date.U.K.
(2)In sub-paragraph (1) above—
“allowable capital losses” means losses which are allowable losses for the purposes of corporation tax on chargeable gains;
“unallowed capital losses” means any allowable capital losses which have accrued to NIE before the transfer date, in so far as they have not been allowed as deductions from chargeable gains.